https://www.taxtmi.com/caselaws?id=450653 The MP HC dismissed an appeal filed against ITAT's order, ruling that no substantial question of law arose for consideration. The ITAT had correctly held that the assessee properly offered net amount to tax, deleted AO's additions, and found the case reopening constituted impermissible change of opinion under Section 147. The HC emphasized that appeals under Section 260A require substantial questions of law, not factual disputes disguised as legal questions. Since ITAT passed a well-reasoned order addressing all grounds and being the final fact-finding authority, the HC found no perversity warranting interference with concurrent findings of CIT(A) and ITAT. en-us Mon, 26 Feb 2024 00:00:00 +0530 Sat, 09 Mar 2024 13:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450653 The MP HC dismissed an appeal filed against ITAT's order, ruling that no substantial question of law arose for consideration. The ITAT had correctly held that the assessee properly offered net amount to tax, deleted AO's additions, and found the case reopening constituted impermissible change of opinion under Section 147. The HC emphasized that appeals under Section 260A require substantial questions of law, not factual disputes disguised as legal questions. Since ITAT passed a well-reasoned order addressing all grounds and being the final fact-finding authority, the HC found no perversity warranting interference with concurrent findings of CIT(A) and ITAT. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450653